Matter of Fitzpatrick, 26 I&N Dec. 559 (BIA 2015) (noncitizen who has voted in a federal election, in violation of 18 U.S.C. 611(a), is removable under INA 237(a)(6)(A), 8 U.S.C. 1227(a)(6)(A) (2012), regardless of whether the alien knew that he or she was committing an unlawful act by voting).

Matter of Fitzpatrick, 26 I&N Dec. 559 (BIA 2015) (noncitizen who has voted in a federal election, in violation of 18 U.S.C. 611(a), is removable under INA 237(a)(6)(A), 8 U.S.C. 1227(a)(6)(A) (2012), regardless of whether the alien knew that he or she was committing an unlawful act by voting).

Note: This conviction does not constitute a crime involving moral turpitude, because a scienter of strict liability is insufficiently culpable to qualify. See Leocal v. Ashcroft, 543 U.S. 1 (2004).

De La Paz v. Coy, __ F.3d __ (5th Cir. May 14, 2015) (noncitizens may not pursue Bivens claims against CBP agents; these claims should be pursued in civil immigration proceedings), citing Mirmehdi v. United States, 689 F.3d 975 (9th Cir. 2011) (no Bivens claim for constitutionally invalid immigration detention); Arar v. Ashcroft, 585 F.3d 559 (2d Cir. 2009) (en banc)

Kamara v. Lynch, __ F.3d __ (5th Cir. May 18, 2015) (sole legal custody requirement for purposes of derivative citizenship only applies where divorced parents entered in to a child custody arrangement; where no custody arrangement exists, the test is whether naturalized parent had actual uncontested custody over child).

Patterson v. Wagner, ___ F.3d ___, 2015 WL 1963541 (9th Cir. May 4, 2015) (order certifying petitioner for extradition to South Korea on murder charge did not violate the 1998 extradition treaty's time-of-lapse provision, or the double-jeopardy provision of the Status of Forces Agreement (SOFA) governing American military personnel).

Garcia v. Lynch, ___ F.3d ___, 2015 WL 2385402 (9th Cir. May 20, 2015) (waiver of appeal from removal order was not considered and intelligent because the decision was based upon an Immigration Judge's incorrect advice).

Mtoched v. Lynch, ___ F.3d ___, 2015 WL 2445063 (9th Cir. May 22, 2015) (United States immigration laws may be applied and enforced within CNMI to noncitizens who entered that territory, committed the crime, and suffered the conviction upon which the removal order is based prior to the extension of United States immigration laws to the Commonwealth).

Walker v. U.S. Atty. Gen., ___ F.3d ___, 2015 WL 1782677 (11th Cir. Apr. 21, 2015) (Florida conviction of uttering a forged instrument, under Fla. Stat. 831.02, is categorically an aggravated felony fraud or deceit offense, under INA 101(a)(43)(M)(i), 8 U.S.C. 1101(a)(43)(M)(i), because the violator utters and publishes as true something that the violator know[s] to be false, whether this is done with intent to injure or intent to defraud).

Arias-Minaya v. Holder, 779 F.3d 49 (1st Cir. Feb. 27, 2015) (immigration judge is not barred from considering police reports containing hearsay in determining whether noncitizen deserves relief as a matter of discretion, even where noncitizen was never convicted), citing Paredes"Urrestarazu v. INS, 36 F.3d 801, 810 (9th Cir.1994); Parcham v. INS, 769 F.2d 1001, 1005 (4th Cir.1985).

Chavez-Alvarez v. Attorney General, 783 F.3d 478, 484 (3rd Cir. Apr. 16, 2015) (government failed to show noncitizens sentence for violation of Uniform Code of Military Justice Article 125, 10 U.S.C.